PAC: GIP Timeline Reduction Tariff Edits (IPWG003) (20210811)

Savion, LLC (“Savion”) would like to thank MISO for bringing this item to stakeholders for discussion. In the August 11, 2021 meeting of the Planning Advisory Committee (PAC), MISO presented proposed tariff edits for Generator Interconnection Procedure (GIP) timeline reduction.

Savion has submitted comments on GIP Timeline Reduction in the past expressing our concerns.  And while MISO has compromised in some regards, the fundamental issue that MISO cannot complete studies on time is not addressed.

MISO continues to delay current study schedules for both internal MISO delays and external affected systems delays.  Without improvement on these core problems, any changes to the schedule timelines will be meaningless.  Savion holds that MISO is complicating the GIP process with little value add. 

Savion recommends that MISO demonstrate the ability to complete studies on these timelines.  MISO risks failing to meet these tighter requirements and additional missed deadlines.

The Environmental Sector appreciates the work that MISO and the IPWG have done to develop a proposal that would both shorten the overall length of the Generator Interconnection Process (GIP), and allow more opportunities for coordination between GI studies and the other relevant MTEP studies, including evaluating GI Network upgrades as Market Efficiency Projects, while in Phases 1, 2 and 3 of the GIP.  While there are some aspects of the GIP that still need to be addressed as discussed below, this proposal is a positive step forward and demonstrates MISO’s national leadership on interconnection reform.

The GIP has always been a lengthy process that impedes a developers' ability to assess the viability of a project through certainty of Network Upgrade costs.  The earlier in the process an interconnection customer (IC) receives accurate interconnection-cost information the sooner they can make an informed decision on moving forward.  One of the key aspects of MISO’s proposed time reduction in the GIP is the option for parallel GIA Negotiations while the studies are being completed.  This change both reduces the overall time for an IC and increases the risk.  Thus we appreciate MISO’s proposal offering two paths for GIA negotiation, one in parallel with studies, and one sequential with lower risk.

Two areas of GIP changes we encourage MISO to continue exploring further are in Affected Systems studies and alignment with other MTEP study processes.  Affected Systems studies can often lag well behind MISO’s GIP, and this may be exacerbated with a more efficient MISO GIP as proposed.  Without full cost information from Affected Systems studies, the risk for ICs increases when signing an interconnection agreement.  We strongly urge MISO to consider how this risk can be mitigated until ICs receive final cost information from their Affected Systems studies, such as options for penalty-free withdrawal.

The Coordinated Planning Process Task Team was considering how to evaluate required interconnection network upgrades to see if they might qualify as Market Efficiency Projects.  While this effort was put on pause in order to focus on the Long Range Transmission Planning process, we think this effort should be continued in the future, as one of the key benefits of a shortened GIP timeline.   We also encourage MISO to consider other ways that the MTEP and GIP processes can be better aligned, such as incorporating the latest MTEP upgrades/models into interconnection studies, once the timelines are more similar.

Again, we thank MISO for this effort and appreciate the opportunity to continue to provide support and input on ways to further improve the GIP and better align it with the MTEP study processes. 

Respectfully submitted,

MISO Environmental Sector

The MISO Transmission Owners (Owners or TOs) provide the following feedback proposed tariff edits for Generator Interconnection Procedure (GIP) timeline reduction presented by MISO at the August 11, 2021 meeting of the Planning Advisory Committee (PAC).

In general, the Owners support MISO’s proposal and appreciate MISO’s efforts to reduce the GIP Timeline and to an annual cycle that can be more closely aligned with MTEP.

The one aspect of MISO’s proposal that is still a concern for some Owners relates to the overlapping processes that may cause re-work, and the disparity between the Interconnection Customer and Transmission Owners’ rights to delay the commencement of GIA negotiations before Network Upgrades identified in System Impacts Studies have been determined by the TO to be feasible. 

• From a practical perspective, the TO is in the best position to know if there is reason to delay GIA negotiation due to questions regarding the feasibility of Network Upgrades identified in the System Impact Study.  Changes to the Network Upgrades needed for a project have a significant potential to impact the aspects of the project that the Transmission Owner is committing to in the GIA, and as previously mentioned there are many reasons why amending a GIA that has been filed at FERC is a cumbersome path forward at best.
• From the Interconnection Customer perspective, the proposed relies heavily on Planning Level estimates provided in the DPP Phase 3, and while costs will always be subject to change when the solutions are fully scoped, the Transmission Owner would is also in the best position to identify the potential for material changes in the estimated cost of the these upgrades.  
• With regard to the IC option to build, requiring the IC to make that election during the Interconnection Facilities study phase, and only allowing the option to build for Standalone Network Upgrades would limit uncertainty late in the GIA negotiation process.  For clarity, any new BPM language must note that a TO’s election to self-fund and the IC’s option to build are not mutually exclusive per the June 18, 2020, FERC Order on Rehearing in Docket ER19-1823-002, ER19-1960-001, and ER19-1960-002.  Rather, MISO needs to develop specific BPM and/or GIP language on the mechanics of how these two options will work together.  For example, it could be structured as the IC invoicing the TO for costs on a regular ~monthly basis, or a TO could pay an estimated amount and takes ownership of the facilities just prior to “in service” with reconciliation of actual costs occurring within, for example, 6 months.

 Finally, the Owners appreciate MISO’s effort to improve the clarity of the Amendment process by including language clarifying that a change in Network Upgrades could necessitate an amendment to the GIA, but this change does not address concerns relating to modeling issues that are created with the GIA on file does not represent relevant aspects of the project, like the COD or facilities required for interconnection, and the Owners request that MISO give further consideration to addressing this concern.